Counting observations isn't reducing incidents

Behaviour-based safety (BBS) rests on a defensible idea: most incidents involve an at-risk act, so watch for the acts and coach them out. The trouble is what happens the moment you attach a number to it. Set a target of two observations per supervisor per week, and you have defined success as the production of observation cards. Cards will appear. Whether risk moved is a separate question the target does not ask.

The metric answers a question you did not mean to ask

An observation count is a proxy. It stands in for “we are watching the work and correcting hazards,” but it measures only “forms were completed.” Those come apart fast under pressure. When the KPI is volume, the cheapest way to hit it is to observe easy, low-stakes behaviours, a colleague already wearing safety glasses at a desk, and log the checkmark. The hard observations, near live energy or at height, are exactly the ones a volume target discourages, because they cost time and social capital per card.

There is a nastier failure mode regulators have named. When observation programs are paired with rate-based incentives, bonuses tied to lower reported injuries, pressure can flip from finding hazards to suppressing reports. OSHA’s 2012 interpretation on safety incentive policies warns that programs disqualifying workers from a reward after an injury “might have dissuaded reasonable workers from” reporting, and that vague rules such as requiring an employee to “maintain situational awareness” can be a pretext to blame the injured (US; anti-retaliation basis 29 CFR 1904.35). A program can post a rising observation curve and a falling recordable rate at once, and the second can be an artifact of the first.

None of this condemns watching the work. It condemns paying for it by the pound. A leading indicator is only leading if it moves before the outcome and points at something you then fix. Count the fixes, not the forms.